# AMERIGAS PROPANE LP — Notice of Amendment

- **operation:** document
- **citation:** CPF 52025019NOA
- **title:** AMERIGAS PROPANE LP — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2025-04-24
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.303, 192.605(a), 192.605(b)(1), 192.605(b)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025019noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025019noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-52025019noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/52025019NOA
**body:**

Notice of Amendment involving AMERIGAS PROPANE LP. PHMSA's enforcement data identifies the cited regulations as 192.303,  192.605(a),  192.605(b)(1),  192.605(b)(2). The case was opened on 2025-04-24 and is reported as closed as of 2026-02-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

52025019NOA_Notice of Amendment_04242025_(24-297238).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025019NOA/52025019NOA_Notice%20of%20Amendment_04242025_(24-297238).pdf

52025019NOA_Notice of Amendment_04242025_(24-297238)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025019NOA/52025019NOA_Notice%20of%20Amendment_04242025_(24-297238)_text.pdf

52025019NOA_Operator Response to Notice_05222025_(24-297238).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025019NOA/52025019NOA_Operator%20Response%20to%20Notice_05222025_(24-297238).pdf

52025019NOA_Region Withdrawal of Notice Letter_02042026_(24-297238).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025019NOA/52025019NOA_Region%20Withdrawal%20of%20Notice%20Letter_02042026_(24-297238).pdf

52025019NOA_Region Withdrawal of Notice Letter_02042026_(24-297238)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52025019NOA/52025019NOA_Region%20Withdrawal%20of%20Notice%20Letter_02042026_(24-297238)_text.pdf

52025019NOA_Notice of Amendment_04242025_(24-297238)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: Kevin.Kelleher@amerigas.com
April 24, 2025
Mr. Kevin Kelleher
Vice President – Supply & Logistics and Operations
AmeriGas Propane Corporation
500 N. Gulph Road
King of Prussia, PA 19406
CPF 5-2025-019-NOA
Dear Mr. Kelleher:
From September 16 to September 20, 2024, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.), inspected the AmeriGas Propane LP Services
(AmeriGas) on the island of Oahu in the state of Hawaii.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
AmeriGas’s plans or procedures. The items inspected and the inadequacies are described below:
1. § 192.303 Compliance with specifications or standards.
Each transmission line or main must be constructed in accordance with
comprehensive written specifications or standards that are consistent with this part.
AmeriGas’s procedures were inadequate to maintain pipeline safety as they did not contain
detailed specifications or standards consistent with subpart G as required. Specifically, during
the inspection, PHMSA reviewed AmeriGas’s Operations and Maintenance Procedure Manual,
Construction of Mains, which was updated on July 31, 2024. During that review, PHMSA
observed that the manual did not include a procedure for the installation of plastic pipeline mains
terminating aboveground consistent with § 192.321(i). In addition, the manual also lacked a



procedure that included the appropriate underground clearance when installing a transmission
line consistent with § 192.325(a).
Therefore, AmeriGas must revise its Operations and Maintenance Procedure Manual,
Construction of Mains to be consistent with the requirements of subpart G.
2. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once each
calendar year. This manual must be prepared before operations of a pipeline
system commence. Appropriate parts of the manual must be kept at locations
where operations and maintenance activities are conducted.
AmeriGas’s procedures were inadequate to maintain pipeline safety because they did not contain
specific instructions detailing how operator personnel would go about performing the specified
tasks listed within the manual. During the inspection, PHMSA reviewed AmeriGas’s Operations
and Maintenance (O&M) manual in its entirety. The PHMSA inspector observed during their
review that the O&M manual was nearly verbatim to the requirements of Part 192 and did not
include the specificity required to carry out the procedures. PHMSA observed that the O&M
lacked such information as who was to perform which tasks, how that person(s) was to be
qualified to perform those tasks, what tasks were to be performed when, where personnel were to
be located when performing these tasks, instructions on how each task was to be performed,
what equipment was to be utilized during the performance of said task, how that information was
to be recorded, analyzed, and retained, and next steps at the end of the task. While in many
instances, what, when and how a task is performed can be gleaned from the pipeline safety
regulations, the remaining steps are determined by the pipeline operator for its specific system
and documented as procedures within its O&M, in accordance with § 192.605(a).
AmeriGas must amend its O&M in its entirety to include specific instructions detailing how its
personnel would perform each of the tasks specified by the pipeline safety regulations, as
required.
3. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . .
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and Subpart M of this part.



AmeriGas’s procedures were inadequate to maintain pipeline safety as they did not contain
procedures for operating, maintaining, and repairing the pipeline in accordance with each of the
requirements of subpart L. Specifically, during the inspection, PHMSA reviewed AmeriGas’s
Operations and Maintenance Procedure Manual, Maximum Allowable Operating Pressure,
which was updated on July 31, 2024. During that review, PHMSA observed that the manual had
not been updated with the latest Table 1 from 192.619(a)(2)(ii) on how to determine maximum
allowable operating pressure (MAOP) pursuant to the requirements of § 192.619(a)(2)(ii).
Therefore, AmeriGas must revise its Operations and Maintenance Procedure Manual, Maximum
Allowable Operating Pressure, to include allowing an operator to calculate its MAOP pursuant to
the requirements of § 192.619(a)(2)(ii).
4. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . .
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) …
(2) Controlling corrosion in accordance with the operations and maintenance
requirements of Subpart I of this part.
AmeriGas’s procedures were inadequate to maintain pipeline safety as they did not contain
procedures for controlling corrosion in accordance with the operations and maintenance
requirements of subpart I. Specifically, during the inspection, PHMSA reviewed AmeriGas’s
Operations and Maintenance Procedure Manual, Corrosion Control, which was updated on July
31, 2024. During that review, PHMSA observed that the manual lacked a procedure requiring
electrically isolated metal alloy fittings installed after January 22, 2019, not meeting the
requirements of § 192.455(f), to be catholically protected and maintained as required pursuant to
§ 192.455(g). In addition, PHMSA observed that the manual failed to include a procedure
requiring each reverse current switch, each diode, and each interference bond whose failure
would jeopardize structure protection to be electrically checked for proper performance six times
a calendar year at intervals not to exceed 2 ½ months as required per § 192.465(c).
Therefore, AmeriGas must revise its Operations and Maintenance Procedure Manual, Corrosion
Control, to include procedures for controlling corrosion in accordance with the operations and
maintenance requirements of subpart I.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings.
Please refer to this document and note the response options. Be advised that all material you
submit in response to this enforcement action is subject to being made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5



U.S.C. § 552(b), along with the complete original document you must provide a second copy of
the document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment
under 5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue an Order Directing Amendment. If your
plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend
your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not
contesting this Notice, we propose that you submit your amended procedures to my office within
60 days of receipt of this Notice. This period may be extended by written request for good
cause. Once the inadequacies identified herein have been addressed in your amended
procedures, this enforcement action will be closed.
It is requested (not mandated) that AmeriGas Propane Corporation maintain documentation of
the safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Director,
Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 5-2025-019-NOA and, for each document you
submit, please provide a copy in electronic format whenever possible.
Sincerely,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Gilliam (#24-297238)
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings

52025019NOA_Region Withdrawal of Notice Letter_02042026_(24-297238)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
12300 W. Dakota Ave., Suite 340
Lakewood, CO 80228
WITHDRAWAL of NOTICE LETTER
VIA ELECTRONIC MAIL TO: Michael.Sharp@amerigas.com
February 4, 2026
Mr. Michael Sharp
President/CEO
AmeriGas Propane LP
500 N. Gulph Road
King of Prussia, PA 19406
CPF 5-2025-019-NOA
Dear Mr. Sharp:
From September 16 to September 20, 2024 AmeriGas Propane LP (AmeriGas) was issued a
Notice of Amendment letter for the case number referenced above. This Notice cited AmeriGas
for compliance with § 192.303, and amendments under §§ 192.605(a), 192.605(a)(1), and
192.605(a)(2).
AmeriGas sold these Hawaii assets in 2025 to Hawaii Gas.
This letter is to inform you that PHMSA hereby withdraws the Notice and that the case is now
closed.
Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration



cc: PHP-60 Compliance Registry
PHP-500 J. Gilliam (24-297238)
Pamela Cannon, Sr. Director, AmeriGas Propane LP, pamela.cannon@amerigas.com
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